JAPAN GRACE PRIVACY POLICY

This Privacy Policy (the “Policy”) sets out how JAPAN GRACE CO., Ltd. (“JAPAN GRACE”) collect, use, and disclose an individual customer’s Personal Data (as defined below) in order to provide services to a customer.

For the purposes of this Policy, in line with the provisions under the Malaysia Personal Data Protection Act 2012 (No. 26 of 2012) (the “Act”), “Personal Data” shall mean data, whether true or not, about an individual customer who can be identified — from that data; or from that data and other information which an organisation has or is likely to have access. Such Personal Data shall also refer to that which is already in the possession of JAPAN GRACE or that which shall be collected by JAPAN GRACE in future.

JAPAN GRACE is committed to protecting your privacy. JAPAN GRACE undertakes to use reasonable endeavours to ensure that all collection and/or usage and/or disclosure of Personal Data by JAPAN GRACE shall be done in a manner and for purposes which are consistent with this Policy and with the Act. JAPAN GRACE has internally established Personal Data Protection Management System, ensuring that all officers and employees recognize and comply with the Act and the Policy and that the system is continuously improved and kept updated.

[Tokyo] +81-03-5908-2505 (10:00～18:30 for Mon.---Fri., 11:00 - 16:30 for Sat. and no service on Sun. & national holidays)

[Osaka] +81-06-6133-0320 (10:00～18:30 for Mon.---Fri., 11:00 - 16:30 for Sat. and no service on Sun. & national holidays)

Statement of Practices on Handling Personal Data

1. General

JAPAN GRACE may collect, use, and disclose any information you enter on our website or give us through various means, including telephone calls, emails, enquiries or bookings at our sales office, SMS, fax, post, and any platforms used by us from time to time. The information which JAPAN GRACE collects includes information that can identify you, including, but not limited to, your name, contact numbers, postal and email addresses, contact preferences, and, if you make a reservation with us, your credit card information. We may also request you to provide us with information on your travel preferences, the loyalty and frequent flyer programmes which you participate in, and feedback, testimonials, photographs and videos of the trip which you booked with us.
A customer has a choice to provide JAPAN GRACE with JAPAN GRACE his/her Personal Data or not, and the customer is kindly requested to recognize and acknowledge that the customer may not be provided a product or service of JAPAN GRACE, unless the customer provides JAPAN GRACE with relevant particulars of Personal Data which are indispensable for JAPAN GRACE’s service requested by the customer.

2. Types of Personal Data Collected

As part of its day-to-day activity, JAPAN GRACE may collect from you, through various means, including via our websites, marketing events, social networking sites and any forms used by JAPAN GRACE from time to time, some or all of the following Personal Data:
• Financial information such as credit card details
• Medical details/health information
• IP Addresses
• Personal contact information such as names, email addresses, mailing addresses, passport details and contact numbers
• Photographs and images

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3. Purpose of Collection and Use of Personal Data

JAPAN GRACE will use your Personal Data for the following purposes:
• To provide you with the products and services you request
• To provide you with travel confirmation and updates
• To manage your account, including processing bills and providing travel notifications
• To communicate with you in general
• To respond to your questions and comments
• To allow us to contact you for customer service, if necessary
• To measure interest in and improve our products, services, and website
• To customise your experience on our website
• To resolve disputes, collect fees, or troubleshoot problems
• To prevent potentially prohibited or illegal activities
• To enforce our Terms and Conditions when you make a travel booking with us
• As otherwise notified to you at the point of collection
The above Personal Data mentioned is also collected for the purposes of:, amongst others, conducting data/market research, analysis and evaluation, providing benefits and/or compensation, processing payment, providing you with any goods and/or services, marketing and communication, delivery of products and services, accounting and auditing, investigating complaints, claims and disputes, responding to inquiries and provide customer services, as well as verification of identity of clients.
JAPAN GRACE stores the Personal Data provided by customer at the time of request of travel arrangement in its database.

4. Disclosure of Personal Data

In order to carry out the functions described above, JAPAN GRACE may, from time to time, disclose your Personal Data between JAPAN GRACE’s companies.
Without derogating from any of the above, JAPAN GRACE may also disclose the data subject’s Personal Data to third parties such as accounting firms; embassies; service providers; lawyers; credit, debit and charge card companies, banks and other entities processing payment; potential buyers or investors of JAPAN GRACE or any of JAPAN GRACE’s companies; and any agent or subcontractor providing services on JAPAN GRACE’s behalf for the provision of JAPAN GRACE’s services.
JAPAN GRACE may disclose your Personal Data to the abovementioned parties also in the occurrence of any of the following events:
• To the extent that JAPAN GRACE is required to do so by the law;
• In connection with any legal proceedings or prospective legal proceedings;
• To establish, exercise or defend JAPAN GRACE’s legal rights;
• To the purchaser (or prospective purchaser) of any business or asset which JAPAN GRACE is (or is contemplating) selling;
• To any person and/or entity for the purpose of processing such information on JAPAN GRACE’s behalf;
• To third parties who provide services to JAPAN GRACE or on its behalf;
• To any third party that purchases JAPAN GRACE or JAPAN GRACE’s business or any part of JAPAN GRACE or JAPAN GRACE’s business;
• With your consent; and
• For the purposes of disaster recovery.

5. Procedure for Access to and Correction of Personal Data

In accordance with the Act, JAPAN GRACE has established a procedure for receiving and responding to any inquiry or request that may arise with respect to the application of this Act.
When a customer requests access to and/or correction of his/her Personal Data, or when a customer requests JAPAN GRACE to delete his/her Personal Data or to cease disclosing the data to a third party, the customer is kindly requested to get in touch with the following contact windows of JAPAN GRACE so that the customer is guided a necessary procedure.
JAPAN GRACE responds to the inquiry or request within a reasonable period in accordance with the Act and the company codes and informs the result to the customer.
In case JAPAN GRACE cannot meet the request partially or wholly, JAPAN GRACE explains the reason to the customer.Personal Data Inquiry Window Contact: Customer Service Center of JAPAN GRACE. Co. Ltd. [Tokyo] +81-03-5908-2505 (10:00～18:30 for Mon.---Fri., 11:00～16:30 for Sat. and no service on Sun. & national holidays)[Osaka] +81-06-6133-0320 (10:00～18:30 for Mon.---Fri., 11:00～16:30 for Sat. and no service on Sun. & national holidays)

6. Optional Provision of Personal Data

In some instances, you may also be requested to provide certain Personal Data that may be used to further improve JAPAN GRACE’s products and services and/or better tailor the type of information presented to you. In most cases, this type of data is optional although, where the requested service is a personalised service, or provision of a product or dependent on your providing all requested data, failure to provide the requested data may prevent JAPAN GRACE from providing the service to you. This type of data includes, but is not limited to:
• Your age;
• Gender;
• Salary range and employment details;
• Education and Profession;
• Hobbies and leisure activities;
• Other related products and services subscribed to; and
• Family and household demographics.

7. Accuracy of Personal Data

Where possible, JAPAN GRACE will validate data provided using generally accepted practices and guidelines. This includes the use of check sum verification on some numeric fields such as account numbers or credit card numbers. In some instances, JAPAN GRACE is able to validate the data provided against pre-existing data held by JAPAN GRACE. In some cases, JAPAN GRACE is required to see original documentation before we may use the Personal Data such as with Personal Identifiers and/or proof of address.

8. Protection of Personal Data

JAPAN GRACE uses commercially reasonable physical, managerial, and technical safeguards to preserve the integrity and security of your Personal Data and will not knowingly allow access to this data to anyone outside JAPAN GRACE, other than to you or as described in this Policy.
However, JAPAN GRACE cannot ensure or warrant the security of any information you transmit to JAPAN GRACE and you do so entirely at your own risk. In particular, JAPAN GRACE does not warrant that such information may not be accessed, altered, collected, copied, destroyed, disposed of, disclosed or modified by breach of any of JAPAN GRACE’s physical, technical, or managerial safeguards.

9. Retention of Personal Data

JAPAN GRACE will delete, as reasonably possible, or otherwise anonymise any Personal Data in the event that the Personal Data is not required for any reasonable business or legal purposes of JAPAN GRACE and where the Personal Data is deleted from JAPAN GRACE’s electronic, manual, and other filing systems in accordance with JAPAN GRACE’s internal procedures and/or other agreements.

10. Transfer of Personal Data Overseas

Your Personal Data may be processed by JAPAN GRACE, its affiliates, agents and third parties providing services to JAPAN GRACE, in jurisdictions outside of Malaysia. In this event JAPAN GRACE will comply with the terms of the Act.

11. Contacting You

To the extent that any of the communication means which you have provided JAPAN GRACE with (which may include, your telephone number and fax number) is/will be listed on the Do Not Call Registry (the “DNC”), by indicating on the Booking Form, or by any other means of indication, you hereby grant JAPAN GRACE your clear and unambiguous consent to contact you using all of your communication means you have provided to JAPAN GRACE including using via voice calls, SMS, Whatsapp, MMS, fax or other similar communications applications or methods, for the purposes as stated above. This will ensure your continued enjoyment of JAPAN GRACE’s promotional rates and services.

12. Change in Policy

JAPAN GRACE reserves the right to alter any of the clauses contained herein in compliance with local legislation, and for any other purpose deemed reasonably necessary by JAPAN GRACE. You should look at these terms regularly. If you do not agree to the modified terms, you should inform us as soon as possible of the terms to which you do not consent. Pending such notice, if there is any inconsistency between these terms and the additional terms, the additional terms will prevail to the extent of the inconsistency.

13. Governing Law

This Policy is governed by and shall be construed in accordance with the laws of Malaysia. You hereby submit to the non-exclusive jurisdiction of the Malaysia courts.

14. Miscellaneous

This Policy only applies to the collection and use of Personal Data by JAPAN GRACE. It does not cover third party sites to which we provide links, even if such sites are co-branded with our logo. JAPAN GRACE does not share your Personal Data with third party websites. JAPAN GRACE is not responsible for the privacy and conduct practices of these third party websites, so you should read their own privacy policies before disclosure of any Personal Data to these websites.
JAPAN GRACE will not sell your Personal Data to any third party without your permission, but we cannot be responsible or held liable for the actions of third party sites which you may have linked or been directed to JAPAN GRACE’s website.
JAPAN GRACE’s websites do not target and are not intended to attract children under the age of 18 years old. JAPAN GRACE does not knowingly solicit Personal Data from children under the age of 18 years old or send them requests for personal data.